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Simone v. Kerensky CA2/2
Appellant Stacy E. Simone (Stacy) appeals from a move-away order made after a judgment dissolving marriage. Specifically, Stacy challenges that part of the order allowing respondent Eric M. Kerensky (Eric) to divert $1,000 of his monthly support arrearages into a travel trust. We agree with Stacy that this portion of the move-away order must be reversed because accrued support cannot be modified and because the trial court did not make an analysis of each parent’s ability to pay travel expenses related to Eric’s visitation with the couple’s children. Accordingly, the matter is remanded for such an analysis.

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